Clean Closure Verification of CCR Surface Impoundments Butch Parton, Jacobs Engineering Emme Mayle, GeoEngineers, Inc.
Clean Closure Verification of CCR Surface Impoundments
Butch Parton, Jacobs EngineeringEmme Mayle, GeoEngineers, Inc.
Introduction§ Butch Parton
– 35 years of civil engineering experience – 6 ½ years as field engineer for Kingston Ash Recovery Project– Other CCR clients and other environmental clean-up clients
§ Emme Mayle– BS in geology, MS in geospatial sciences– Manages field sampling teams for all media– Experienced in data acquisition, data management and GIS
modeling
CCR Rule§ 40 CFR Part D 257.102(a)
– Closure of a CCR landfill, CCR surface impoundment, or any lateral expansion of a CCR unit must be completed either by leaving the CCR in place and installing a final cover system or through removal of the CCR and decontamination of the CCR unit, as described in paragraphs (b) through (j) of this section
CCR Rule Continued§ 40 CFR Part D 257.102(c)
– Closure by removal of CCR. An owner or operator may elect to close a CCR unit by removing and decontaminating all area affected by releases from the CCR unit. CCR removal and decontamination of the CCR are complete when the constituent concentrations throughout the CCR unit and any areas affected by releases from the CCR unit have been removed and groundwater monitoring concentrations do not exceed the groundwater protection standard established pursuant to 257.95(h) for constituents listed in appendix IV to this part
Clean Closure Verification§ Stepwise method for determining “clean” closure of
CCR impoundments – Relatively simple– Based on scientific statistical analysis
§ Method accepted by EPA and other regulatory agencies
Step 1 – Removal of All Visible Ash§ Use typical earth moving equipment to remove ash to
lines and grades of excavation plans
Step 2 – Field Screening§ Accomplished using one or combination of following:
– Visual observation– “Feel” test– On-site microscope
Step 3 – Sampling Approach§ Visual Sampling Plan (VSP)
– Software tool developed for Department of Energy (DOE) – Supports development of defensible sampling plan based on:
§ Statistical sampling theory § Statistical analysis of sample results to support confident
decision making
§ VSP couples site and sample location visualization capabilities with optimal sampling design and statistical sample analysis strategy
Step 4 – Quality Assurance Project Plan (QAPP)
§ EPA: Describes the activities of an environmental data operations project involved with the acquisition of environmental information
§ EPA: Documents the results of a project’s technical planning process, providing clear, concise, and complete plan for the environmental data operation and its quality objectives and identifying key project personnel.
Step 5 – Collecting Samples§ Surveying§ Grid layout§ Sample location§ Sampling equipment§ Sampling techniques§ Documentation of sampling procedures§ GIS mapping
Step 5 – Collecting Samples§ Soil samples collected directly
into glass jars using clean tools and disposable nitrile gloves
– Prevents cross-contamination
§ Duplicates collected§ Packed in containers§ Sent to laboratory
with chain of custody
What Does Chain of Custody Include?§ List of all samples
in shipment§ All testing to be
done by laboratory§ Sample collection
date and time § All parties with
custody since collection
– Sampler, project manager, or lab personnel not testing the sample
Step 6 – Polarized Light Microscopy (PLM)§ Microscope with pair of polarizing devices in optical
train§ First polarizer defines initial plane of polarization for
light entering microscope § Other polarizer defines plane of polarization of light
reaching ocular tube
Step 6 – Polarized Light Microscopy (PLM) Continued§ Polarized light microscopy allows viewing of absorption
color and optical path boundaries between minerals of differing refractive indices
§ Distinguish between isotropic and anisotropic substances
– Revealing detailed structure and composition of materials
Step 7 – Results§ Results Validated
– Data validation = Reviewing analytical laboratory data to ensure data were generated in compliance with proper analytical methods and procedures
– Typically performed by party independent of laboratory generating data
§ Certification Report– Compiles all drawings, data and other information in single
document– Certified by Professional Engineer for compliance to
CCR Rule
Summary§ Simple procedure based on scientific statistical
analysis§ Accepted by EPA and other regulatory agencies§ Procedure is documented by surveying, GIS mapping,
chain-of-custody procedures, and laboratory reports§ Certification Report documents compliance with CCR
Rule
Questions?§ Butch Parton, PE, Jacobs Engineering
125 Broadway AvenueOak Ridge, TN [email protected]
§ Emme Mayle, GRIT, GeoEngineers, Inc.3050 South Delaware AvenueSpringfield, MO [email protected]